"A former Harlan clerk, Charles Fried, a distinguished professor of law at Harvard, concluded that it is “likely-but not certain-that Justice Harlan would have dissented in Roe.” Fried went further: “The argumentation of Harlan’s dissent in [Poe v. Ullman[]. . . as well as his refusal to condemn laws proscribing adultery, fornication, and homosexuality leave little doubt that he would have held with the dissenters in Roe.”"
January 1, 1970